Estate of Cook v. Commissioner
At issue is the value at decedent's date of death of her interest in a limited partnership.
Tax Court Values Partnership Interest in Future Lottery payments
This estate tax case concerns 19 annual installment payments of lottery winnings to a limited partnership in which the decedent held a 2% general partnership interest and a 48% limited partnership interest.
Estate of True v. Commissioner
1Cases of the following petitioners are consolidated herewith: Jean D. True, docket No. 3408-98 and Estate of H.A. True, Jr., Deceased, H.A. True, III, Personal Representative, docket No. 3409-98. T.C. Memo. 2001-167 UNITED STATES TAX COURT ESTATE OF H.A. TRUE, JR., DECEASED, H.A. TRUE, III, PERSONAL REPRESENTATIVE, AND JEAN D. TRUE, ET AL.1, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 10940-97, 3408-98, Filed July 6, 2001. 3409-98. Buford P. Berry, Emily A. Parker ...
Buy-Sell Agreements Are Testamentary Devices
This 336-page estate and gift case deals with a $75,935,883 tax deficiency and $30,328,153 in associated penalties asserted by the IRS.
Buy-Sell Agreements Do Not Control for Estate Tax Purposes
The Tax Court considered whether buy-sell agreements controlled the value of the business interests the decedent held for estate and gift tax purposes.
Tax Court Upholds Estate's Fractional Discount for Minority Interest Held by Limited Partnership
This valuation dispute arose from the undivided real estate interest held by the Forbes QTIP trust.
Simplot Reversed by 9th Circuit; Control Premium for Voting Shares Incorrectly Applied
This case is the 9th Circuit Court of Appeals' decision on appeal of Estate of Simplot v. Commissioner, 112 T.C. No.13 (1999), which was abstracted in the May 1999 issue of Shannon Pratt's Business Valuation Update.
9th Circuit Vacates and Remands Tax Court's Valuation in Mitchell
In this ongoing estate tax proceeding, the Estate of Paul Mitchell (Estate) appealed the U.S. Tax Court's decision allowing the Commissioner of the IRS to assess an additional $2,404,571 in federal estate taxes.
Technical Advice Memorandum 9725002
PRIVATE RULING 9725002 INTERNAL REVENUE SERVICE NATIONAL OFFICE TECHNICAL ADVICE MEMORANDUM "This document may not be used or cited as precedent. Section 6110(j)(3) of the Internal Revenue Code."
Valuing an interest in an RELP
A Study of the Discounts Inherent in the P/NAV Multiples of Real Estate Limited Partnerships, Russell T. Glazer , Business Appraisal Practice, Winter 2000-2001, pp.22-28. This article addresses ...
Federal Tax Valuation
FEDERAL TAX VALUATION, Bogdanski, John A. Warren, Gorham & Lamont, 117 East Stevens Avenue, Valhalla, New York 10595, (800) 431-9025. Available for $205, updated twice annually for approxim ...
Recent Court Decisions Point Up Importance of Underlying State Law in Family Partnerships
RECENT COURT DECISIONS POINT UP IMPORTANCE OF UNDERLYING STATE LAW IN FAMILY PARTNERSHIPS , Abraham, Mel H. Valuation Strategies , November/December 2000 This article examines two recent court ca ...
IRC § 7520
LEXSTAT IRC § 7520 INTERNAL REVENUE CODE Copyright 2000, LEXIS Law Publishing, a division of Reed Elsevier Inc. All rights reserved. *** CURRENT THROUGH P.L. 107-7, APPROVED 4/12/01 ...
IRC § 2703
LEXSTAT IRC sec. 2703 INTERNAL REVENUE CODE Copyright 2000, LEXIS Law Publishing, a division of Reed Elsevier Inc. All rights reserved. *** CURRENT THROUGH P.L. 107-7, APPROVED 4/12 ...
IRC § 2704
LEXSTAT IRC § 2704 INTERNAL REVENUE CODE Copyright 2000, LEXIS Law Publishing, a division of Reed Elsevier Inc. All rights reserved. *** CURRENT THROUGH P.L. 107-7, APPROVED 4/12/01 ...
Oppressed Shareholders' Rights Can Affect Estate and Gift Tax Valuation
Greene, Martin, and Douglas Schnapp The CPA Journal , February 2001 This article initially distinguishes the rights of different classes of minority shareholders. Oppressed shareholders' inter ...
Estate of Simplot v. Commissioner (II)
Ninth Circuit reversed and ordered entry of judgment in favor of the estate on remand because the Tax Court erroneously attributed a premium to minority voting stock.
Estate of Hoffman v. Commissioner
At issue is the fair market value of property interests held by decedent at the time of her death.
Appraisers Apply Myriad of Valuation Techniques to Various Estate Holdings
Marcia Hoffman's (decedent) estate held a 27.5% interest in Clubside Partnership, which was family owned.
Estate of Mitchell v. Commissioner (II)
Estate claimed Tax Court erred by failing to provide a detailed explanation of the methodology used to calculate FMV, miscalculating the value, and failing to shift the burden of proof.
Avoiding field audits of estate tax returns; A survey of IRS estate tax attorneys
As a result of IRS staffing reductions, the historic estimate that approximately 38% of 706's receive field audit is high. One IRS attorney estimated the recent field audit percentage to be closer to ...
9th Circuit Reverses Kaufman; Actual Sales Best Evidence
This case is the 9th Circuit Court of Appeals' decision on appeal of Estate of Kaufman v. Commissioner, T.C. Memo 1999-119 (1999), which was abstracted in the May 1999 Business Valuation Update.
The IRS' 'More Reliable' Valuation Accepted Over Estate Valuation
This case involves a hearing on remand from the 9th Circuit to provide sufficient analysis of the consideration value of common and preferred stock in two closely held companies transferred and received by Cyril Magnin, the life estate holder.
More Good News on Estate and Gift Valuation
In this interview with Owen G. Fiore , an estate planning attorney with the Fiore Law Group, CCH, asks Fiore about the new IRS adequate disclosure regulations and the recent case of Kerr v. Commissi ...
Adequate Disclosure of Gifts
FEDERAL REGISTER Vol. 64, No. 232 Rules and Regulations DEPARTMENT OF THE TREASURY Internal Revenue Service (IRS) 26 CFR Parts 20, 25, 301 and 602 [TD 8845] RIN 1545-AW20 Adequ ...